Germany’s Federal Ministry of Finance (BMF) has released a new circular that further defines how e-invoicing errors should be interpreted and managed. This clarification builds on recent regulatory updates such as the amendments to Germany’s tax rules for e-invoicing and the GoBD revisions for 2025. Together, these measures create a more consistent and transparent framework as Germany prepares for the upcoming e-invoicing mandate.
Clarifying the types of e-invoicing errors
The BMF circular introduces new sections (6a, 6b, and 35a) in the VAT application decree, explaining how companies should distinguish between format, business-rule, and content errors. A format error occurs when an e-invoice fails to comply with approved syntaxes, or when essential VAT-relevant fields cannot be extracted from an interoperable format. Such invoices are considered invalid and non-compliant under VAT law.
Business-rule and content validation
Business-rule errors are defined as violations of specific business logic that can result in incorrect invoice content. If these issues affect mandatory VAT information, the e-invoice is deemed incorrect. The BMF also clarifies the concept of a critical error, helping businesses assess which discrepancies have legal or fiscal implications. This complements the technical consolidation of national systems, such as the merger of the ZRE and OZG-RE platforms into a unified e-invoicing infrastructure, simplifying how invoices are exchanged with public administrations.
Validation tools and compliance responsibility
The BMF confirms that companies may rely on a “suitable validation application” to check compliance with format and business rules. However, entrepreneurs remain responsible for verifying the accuracy and completeness of the invoice content itself. Validation reports generated by such applications should be retained as part of a company’s audit documentation. This shared responsibility between automation tools and business oversight reflects the European push for harmonization, illustrated by the Franco-German e-invoicing collaboration that aims to align interoperability and reporting standards across borders.
With this circular, the BMF continues to strengthen Germany’s digital tax ecosystem ahead of the phased rollout of mandatory B2B e-invoicing between 2025 and 2028. The document clarifies technical and compliance expectations, ensuring that businesses are better prepared to meet validation and retention obligations.
The full BMF letter on e-invoicing can be accessed here.
Key takeaways for businesses
- The BMF distinguishes between format, business-rule, and content errors for e-invoicing.
- Format errors make an invoice invalid under VAT law.
- Business-rule errors can lead to incorrect VAT data and non-compliance.
- Validation tools support compliance, but businesses remain fully responsible for accuracy.
- Validation reports must be retained for audits and documentation purposes.
- The clarification complements recent updates to GoBD rules and tax guidance ahead of 2025.
